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IRS Insights - May 2013


Deloitte ImageWelcome to the bimonthly publication, IRS Insights, produced by the Deloitte Tax Controversy Services group to keep our clients abreast of current issues related to the Internal Revenue Service.

In this month's issue:

  • Tax Controversy Updates
    - IRS Chief Counsel Memorandum: Restricted Consent Agreements Extend Refund Statute Only for Items Identified in Consent
    - Ninth Circuit Affirms Denial of Reasonable Cause Relief Where Taxpayer Relied on Advisor to Determine Due Date of Tax Return
    - Tax Court Reverses Position on Applicability of Gross Valuation Misstatement Penalty Where Taxpayer Concedes Deduction on Unrelated Ground
    - Tax Court Dismisses Petition Filed In Response to Invalid FPAA
    - IRS Chief Counsel Memorandum: Penalties under IRC §§ 6721 and 6722 are Divisible for Purposes of Establishing Refund Jurisdiction

See attached file for details.

Visit the IRS Insights archive for issues from the past year.

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